GBBC Response to the ECB Appia Consultation

GBBC has submitted its response to the European Central Bank’s consultation on Appia, the Eurosystem’s roadmap for a future European tokenized wholesale financial ecosystem.

The consultation addresses a set of foundational market-structure questions for tokenized wholesale finance in Europe, including the role of central bank money, the design of common infrastructure, interoperability, standards, strategic autonomy, governance, and public-private collaboration.

In its response, GBBC supports the Eurosystem’s overall direction of travel while making targeted recommendations on the design choices that will determine whether Appia is workable in practice. In particular, GBBC emphasizes the need to:

🔹 Treat interoperability as a core design principle

🔹 Ensure that the scope and governance of any shared utility layer are clearly defined

🔹 Operationalize strategic autonomy through practical legal, operational, and governance criteria

🔹 Build standards through open, market-engaged processes that draw on existing frameworks

🔹 Structure the next phase of Appia through clear and practical public-private collaboration

We are grateful to our members for their contributions to this work and for the practical insights they brought to the development of the response.

GBBC welcomes the Eurosystem’s engagement on these market-structure questions and stands ready to continue supporting the development of a tokenized wholesale framework that is resilient, scalable, and internationally coherent.

Read the full response here.